Opinion
The panel unanimously finds this case suitable for decision without oral argument. See Fed. R.App. P. 34(a)(2).
NOT FOR PUBLICATION. (See Federal Rule of Appellate Procedure Rule 36-3)
Taxpayers sought review of federal income tax determination by Commissioner of Internal Revenue (CIR). The United States Tax Court upheld determination. Taxpayers appealed. The Court of Appeals held that taxpayers had failed to show the existence of a valid debt owed to them, for purposes of bad debt deduction.
Affirmed.
Page 516.
Appeal from the United States Tax Court.
Before LEAVY, THOMAS, and RAWLINSON, Circuit Judges.
This disposition is not appropriate for publication and may not be cited to or by the courts of this circuit except as may be provided by 9th Cir. R. 36-3.
Warren Jack Kidder and Barbara Jeanne Kidder appeal pro se from the tax court's decision upholding the Commissioner of the Internal Revenue's federal income tax determination for the tax years 1992 and 1993. We have jurisdiction pursuant to 26 U.S.C. § 7482. We review de novo the tax court's conclusions of law and for clear error its findings of fact, see Kelley v. Commissioner, 45 F.3d 348, 350 (9th Cir.1995), and affirm.
The tax court did not err in determining that the Kidders failed to establish that a valid debt existed between them and Mr. Bogue for purposes of the bad debt deduction under 26 U.S.C. § 166. See Zimmerman v. United States, 318 F.2d 611, 613 (9th Cir.1963).
AFFIRMED.